Privacy Policy

This privacy statement covers the Web site www.topcoder.com (“Site”) and personally identifiable information about users of our services and products (“Services”) owned and operated by Topcoder, Inc. (“Topcoder”). Because this Site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

EU-U.S. & Swiss Privacy Shield

Topcoder complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Topcoder has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Topcoder is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Topcoder complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Topcoder is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Topcoder may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Dispute Resolution

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at [https://feedback-form.truste.com/watchdog/request].

Any questions, comments or complaints about the data practices (including without limitation compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement) of a hosted online OnBoarding software customer or partner for whom Topcoder processes data should be addressed to that customer or partner.

Privacy Policy Updates

Due to the Internet’s rapidly evolving nature, Topcoder may need to make material changes to this policy or update this Privacy Policy from time to time. If so, Topcoder will post its updated Privacy Policy on our homepage with a prominent material change notice or notify you by email (sent to the e-mail address specified in your account) prior to the to the change becoming effective. If any modification is unacceptable to you, you shall cease using this Site. If you do not cease using this Site, you will be deemed to have accepted the change.

Information Collection, Use, Choices and Data Integrity

You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site, we may invite you to contact us with questions or comments, register for webinars or events, participate in surveys, request information or more information about our Services or log a support case to request technical support. Due to the nature of some of these activities, we may collect personally identifiable information, such as your name, address, email address and phone number, username, password and any other personally identifiable information you elect to include in your communications sent to us. In certain circumstances, we also may ask for your title, company name and additional company information such as annual revenues. We may also ask for demographic information in order to provide you with a more personalized experience.

If you request more information about our Services, we may use your personally identifiable information to send you the information you have requested. We may use your personally identifiable information to register you to use our Site, deliver certain goods, services or information you have requested, provide you with notices regarding Services you have purchased or products and services of our partners you may want to purchase in the future and other Topcoder news, verify your authority to enter the Site and improve the content and general administration of the Site. You have the choice to opt-out of receiving emails from us about our Services or products and services of our partners, including promotions and events and other news. You can opt out of being contacted by us regarding our Services or products and services of our partners, including promotions and events as well as other news at any time by sending an email to support@topcoder.com.

We may receive a confirmation when you open an e-mail from Topcoder if your computer supports this type of program, in order to help us make e-mails more interesting and helpful.

In performing and providing our Services to you, we may have access to personally identifiable information that is included in the data that you provide to us so that we can provide our Services for you. For example, we may have access to certain usernames that you use to login to third party services and websites and data that you store in your accounts with such third party services. We do not store or use such personally identifiable information other than as necessary to perform our Services and provide our Services to you.We use your personally identifiable information for the purposes for which it was collected as set forth above and not for promotional purposes or for use by third parties for promotional purposes.

Cookies and Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by Topcoder and our partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users’ settings (e.g. language preference), and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.

Local Storage Object

We use HTML 5 local storage objects (LSOs) to store content information and preferences [or – other uses]. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information.

Various browsers may offer their own management tools for removing HTML5 LSOs.

Testimonials

We post testimonials on our web site which contain personally identifiable information such as the customer’s name. We do obtain the customer’s consent prior to posting the testimonial to post their name along with their testimonial. If you want to remove your personally identifiable information that is being displayed on our website under public pages please send your request to support@topcoder.com.

## Blogs, Forums and Chatrooms

If you use a bulletin board, blog, or chat room on this Site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at support@topcoder.com. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.

Behavioral Targeting / Re-Targeting

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Onward Transfer

We will share your personal information with third parties only in the ways that are described in this privacy policy.

We may provide or provide access to your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us. For example, a consultant may have access to your personally identifiable information while the consultant is performing services on our behalf if the services require access to your systems. Such third parties are required to agree to a confidentiality agreement with us regarding your personally identifiable information and we only authorize them to use your personally identifiable information that they may have access to as necessary to perform services on our behalf and not for their own marketing purposes. We also may provide your personally identifiable information to our third party business service partners and they may use your personally identifiable information to send you marketing and promotional information. You may opt-out of having your information shared with our third party business service partners by emailing us at: support@topcoder.com.

As part of our provision of Services to you, you may request us to publish your data which may contain personally identifiable information on third party websites.

Other people will be able to view such data if such data is published on third party websites.

We will also disclose your personally identifiable information and the aggregate information if we reasonably believe we are required to do so by law, court order, warrant, lawful requests by public authorities, including to meet national security, subpoena, legal process or regulation or in cooperation with any governmental investigation. We may transfer your personally identifiable information and the aggregate information to a successor entity upon a merger, consolidation or other corporate reorganization in which Topcoder participates or to a purchaser of all or substantially all of Topcoder’s assets to which this Site relates. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information.

Children’s Privacy

Topcoder recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither our Site nor our services are intended for children under the age of 13. Topcoder does not target its services or this Site to children under 13. Topcoder does not knowingly collect personally identifiable information from children under the age of 13.

Access

Upon request Topcoder will provide you with information about whether we hold, any of your personal information. You may correct, amend or delete your personally identifiable information that Topcoder stores, except where the burden or expense to Topcoder of providing access would be disproportionate to the risks to your privacy or where the legitimate rights of persons other than you would be violated. Please email support@topcoder.com to correct, amend or delete your personally identifiable information. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Third Party Sites

The Site may provide links to other Web sites or resources over which Topcoder does not have control (“External Web Sites”). Such links do not constitute an endorsement by Topcoder of those External Web Sites. You acknowledge that Topcoder is providing these links to you only as a convenience, and further agree that Topcoder is not responsible for the content of such External Web Sites. Your use of External Web Sites and any products purchased on such External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

The Topcoder Knowledge Base is powered by Salesforce.com. No personally identifiable information is gathered on these pages.

Security

We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Topcoder may use encryption, password protection and other security measures to help prevent unauthorized access to your personally identifiable information. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. . If you have any questions about the security of your personal information, you can contact us at support@topcoder.com.

Widget

This Site uses the “Add This” widget where personally identifiable information is collected in the form of the invite-a-friend feature. This feature is used to send a one time invite to the third party email address you entered through the widget. The personally identifiable information entered on this widget is subject to the privacy policy of the “Add This” widget. Topcoder shares no responsibility in regards to the personally identifiable information entered through the widget.

You can also import email contacts using this widget. The widget will import email addresses from various email service providers into your account. Once the email addresses are imported you must manually click on each email you address you wish to send a communication to.

Questions

If you have any questions regarding this Privacy Policy please contact us via email at support@topcoder.com or at: